OUR MODERN SLAVERY POLICY

Document details Organisation: The Real Clinic

Current Version Number: 1.3

Date Approved: May 2026

Review Date: May 2028 or before if needed

Signatory 

R Walker

COO

Document Revision History

Document revision history Version and Date

1.1 May 2022

1.2 May 2024

1.3 May 2026

Confidentiality Notice

This document is the property of The Real Clinic Limited. It contains confidential and privileged information protected from unauthorised disclosure. Its contents must not be copied, reproduced, or distributed outside of The Real Clinic without prior written consent.

1. Purpose

This policy sets out The Real Clinic Limited’s (“The Real Clinic”) commitment to preventing modern slavery and human trafficking in our business and supply chains. It is issued in the spirit of the UK Modern Slavery Act 2015 and reflects our belief that all people have the right to be free from slavery, servitude, forced or compulsory labour, and human trafficking.

While The Real Clinic may fall below the turnover threshold that requires a statutory slavery and human trafficking statement under section 54 of the Act, we adopt this policy voluntarily as part of our commitment to ethical business conduct and good corporate governance.

2. Principles

The Real Clinic has a zero-tolerance approach to modern slavery in any part of our business or supply chains. We expect the same high standards from all our contractors, suppliers, and other business partners, and we require them to confirm that they, and their own suppliers, comply with this policy. Acting ethically and with integrity in all our business relationships is central to our values as a healthcare provider.

3. Scope

This policy applies to all persons working for The Real Clinic at all levels, including employees, workers, contractors, agency staff, consultants, and members of the Board. It also extends to our supply chain, including suppliers of medical equipment, pharmaceuticals, office supplies, facilities services, and other goods and services necessary for our operations.

4. Our Structure, Operations and Supply Chain

The Real Clinic operates as a private healthcare provider offering a range of medical services. Our supply chain includes suppliers of medical equipment, pharmaceuticals, office and clinical supplies, facilities management, and other goods and services necessary for our operations. We are committed to working only with suppliers who share our values and adhere to ethical business practices.

5. Modern Slavery Risks and Mitigating Actions

We have assessed our operations and supply chains to identify potential risks of modern slavery. While we have not identified any instances of modern slavery within our business, we take proactive steps to mitigate risk, including:

• Supplier due diligence: operating a robust supplier selection process that assesses prospective suppliers’ commitment to ethical practices and compliance with relevant laws.

• Contracts and agreements: including clauses in our supplier contracts requiring compliance with applicable laws and ethical standards, including those relating to modern slavery.

• Training and awareness: providing training to relevant staff, particularly those involved in recruitment and procurement, to help them identify and report concerns.

• Monitoring and auditing: regularly reviewing our supply chains to check compliance with our ethical standards and identify areas for improvement.

6. Roles and Responsibilities

Overall responsibility for this policy sits with the Board, which oversees The Real Clinic’s approach to human rights, including modern slavery, and approves this policy on a periodic basis, as set out in the Document Revision History above. Day-to-day responsibility for implementation sits with the Compliance Lead, who is responsible for monitoring compliance, updating this policy, and reporting any material concerns to the Board. All managers are responsible for ensuring that those who work for them understand and comply with this policy.

7. Raising a Concern

Employees, suppliers, and other stakeholders are encouraged to report any concerns relating to modern slavery or unethical practices as soon as possible. Reports can be made through a line manager, HR, or via the Clinic’s confidential whistleblowing procedure. All concerns will be taken seriously, investigated promptly, and handled confidentially. No one raising a genuine concern in good faith will suffer any form of retaliation or detriment as a result.

8. Training and Awareness

The Real Clinic provides training on modern slavery awareness to staff, with particular focus on those in recruitment, procurement, and supplier-facing roles, to build their ability to identify and escalate potential red flags

9. Measuring Effectiveness

To assess the effectiveness of the steps we take, we will:

• review and update this policy and related procedures regularly to ensure they remain effective and reflect best practice;

• carry out periodic reviews of our operations and supply chains to assess compliance with our ethical standards; and

• gather feedback from employees, suppliers, and other stakeholders to identify areas for improvement.

10. Review and Approval

This policy is reviewed regularly to reflect legal developments and best practice. To be reviewed every 2 years or before as needed.